Privacy Policy

September 7, 2010

Nomura Corporate Research and Asset Management Inc. ("NCRAM") recognizes that protecting your privacy is important.  We want our customers to understand what information we collect and how we use it.

By using this website, www.NCRAM.com, (the "Website") you are knowingly and willingly agreeing to be bound by our privacy policy.

We have taken measures to ensure that your online experience with us is safe and secure.  This privacy policy (the "Policy") details the information gathering and sharing practices for NCRAM.  Your access and use of the Website indicates your acceptance of this Policy. NCRAM may change this Policy from time to time, so we encourage you to review our Policy whenever you use the Website to make sure you understand how your information will be used.  Your continued use of the Website following the posting of changes to the Policy will signify your acceptance of the then current Policy.  The Policy will include the date we last updated the Policy.

Information We Collect

We may collect the following types of nonpublic, personal information* about you:

• Information about your identity such as your name, address and social security number;
• Information about your transactions with us and/or our affiliates; and
• If you visit our website, information we collect about you via a web server, often referred to as a "cookie". "Cookies" indicate where a site visitor has been online and what has been viewed.

You can choose not to accept the cookie by adjusting your browser settings, but, if you choose to do so, all parts of the Website might not function properly.

*Nonpublic, personal information is nonpublic information about you that we obtain in connection with providing a financial product or service to you.

Confidentiality and Security

We restrict access to nonpublic, personal information about you to those employees who need to know that information to provide services to you.  We also educate our employees about safeguarding customer information and preventing its unauthorized access, disclosure and/or use. We maintain physical, electronic and procedural safeguards to protect your nonpublic, personal information.

What Information We Disclose

We share nonpublic, personal information with our affiliates and other third parties who perform administrative services on our behalf, such as transfer agents and printers to assist us in the distribution of investor materials.  These companies will use the information only for the services for which we hired them and are not permitted to use or share this information for any other purpose.  We understand that the third parties who perform administrative services on our behalf have each adopted policies to safeguard your personal information that comply with federal standards.

We are also permitted by law to disclose nonpublic, personal information about you to other third parties in certain circumstances.  For example, we may be required to disclose nonpublic, personal information about you to government entities such as the IRS for tax purposes.

If you decide at some point either to sell your shares or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice. 

Children Under 13

This Website is not directed at children 13 years of age or younger.  NCRAM, therefore, shall not intentionally collect information about any user under the age of 13.

Third Party Links

The Website may provide links to other third party websites. Even if the third party is affiliated with NCRAM through a business partnership or otherwise, NCRAM is not responsible for the privacy policies or practices or the content of such external links.  These links are provided to you for convenience purposes only, and you access them at your own risk.

Contacting NCRAM

You may contact us if you have any questions about this Policy, the practices of this Website, or your dealings with the Website by contacting our Fund Administration Department at (212) 667-9300.